Letter from Biffa Waste Services Ltd to
the Environment Agency 19 March 2001
RE: REFRIGERATION
EQUIPMENT
EC Regulation 2037/2000 on ozone depleting substances
places significant restrictions on point sources of ozone depleting
chemicals with effect from 1 January 2002 in relation to consumer
products. The regulations have applied since the 1 January 2001
for industrial and commercial arisings but from our perspective
they appear not to have been enforced.
This assumption is applied in relation to refrigeration
equipment. The majority of this material (amounting around 250,000
domestic units monthly weighing 40,000 tonnes) have tended to
be routed to car fragmentation plants where the quality of record
keeping in relation to collection of liquid CFCs is highly variable
and the CFCs contained in the insulating foams are released by
fragmentation and crushing to atmosphere. Our understanding is
that if the regulation as currently framed is applied this latter
practice will become illegal.
The consequence is that retailers will probably
not take an old for new fridge from householders and that 40,000
tonnes of fridges will thus inundate civic amenity sites from
January next year.
Biffa and Michael Baker Group of Companies are
examining the feasibility of investing around £2 million
in a reprocessing plant for fridges but we are reluctant to commit
such investment until we have a clearer understanding from DTI
and DETR as to how the regulations will be enforced. Clearly such
investment will be wasted in the absence of any absolute ban on
the disposal of fridges through car fragmentisation plants. Even
if such a ban is introduced there will be an immediate requirement
for large scale stockpiling of scrap fridges from the 1 January
since we are unlikely to be able to install our plant and equipment
in time.
We are seeking clarification from DTI and DETR
but in the meantime it is now an urgent priority to involve the
Agency in this debate. As a result we are enclosing a copy of
our recommended Code of Practice for the plant and equipment we
have in mind and we would welcome the opportunity to sit down
with your appropriate staff and evaluate how the necessary licensing
procedures can be accelerated to anticipate what we see as a substantial
pollution risk area which has the added potential for significant
public relations damage if not managed within a sensible framework.
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